Raum v. Restaurant Associates, Inc.
This dissenting opinion argues that the plaintiff, a homosexual partner, should have standing to sue for wrongful-death damages under EPTL 5-4.1. The dissent contends that the motion court erred in dismissing the plaintiff's wrongful-death claim by narrowly interpreting 'surviving spouse'. It asserts that denying homosexual partners, who are legally barred from marrying, the right to sue constitutes an invidious distinction violating the Equal Protection Clauses of the State and Federal Constitutions. The opinion references precedents like Braschi v Stahl Assocs. Co. to support a broader, functional interpretation of the statute to promote public welfare, and distinguishes other cases like Matter of Cooper and Matter of Secord v Fischetti. It concludes that excluding homosexual life partners from the class of persons with standing lacks a rational basis, as it is unrelated to the statute's goals, the State's marriage policy, or administrative convenience, and therefore the decision below should be reversed and the wrongful-death claim reinstated.